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DATA POLICY

1. Introduction

1.1

We are committed to safeguarding the privacy of the individuals with whom we interact when administering the business of Peter Spanton Drinks Limited

1.2

This policy applies where we are acting as a data controller with respect to the personal data of our website visitors, suppliers and customers; in other words, where we determine the purposes and means of the processing of that personal data.

1.3

We do not use cookies on our website.

1.4

In this policy, "we", "us" and "our" refer to Peter Spanton Drinks Limited. For more information about us, see Section 8

2.0 How we use your personal data

2.1

In this Section 2 we have set out:

(a)

the general categories of personal data that we may process;

(b)

the purposes for which we may process personal data; and

(c)

the legal bases of the processing.

2.2

We may process your account data ("account data"). The account data may include your name, job title, transaction details, payment details and work email address. The source of the account data is you or your employer. The account data may be processed for the purposes of providing our products, ensuring the security of our services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.3

We may process information contained in any enquiry you submit to us ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling our products to you. The legal basis for this processing is consent.

2.4

We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.

2.5

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of other

2.6

We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.7

In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.8

Please do not supply any other person's personal data to us, unless we prompt you to do so

3.0 Providing your personal data to others

3.1

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.2

In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.0 International transfers of your personal data

4.1

In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2

Some of our IT services providers are situated in the USA. Transfers to the USA will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, and the adoption by our IT service providers of the US Privacy Shield framework, which operates to protect your data to EU standards.

4.3

We have social media accounts with Facebook, Twitter and Instagram. Those social media sites may automatically provide us with access to certain personal information retained by them about you (for example any content you have viewed). Social media providers should provide a way for you to manage your privacy settings within their own interface

5.0 Retaining and deleting personal data

5.1

This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3

Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person

6.0 Amendments

6.1

Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person

6.2

You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3

We may notify you of significant changes to this policy by email.

7.0 Your rights

7.1

In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2

Your principal rights under data protection laws are:

(a)

the right to access;

(b)

the right to rectification;

(c)

the right to erasure;

(d)

the right to restrict processing;

(e)

the right to object to processing;

(f)

the right to data portability;

(g)

the right to complain to a supervisory authority; and

(h)

the right to withdraw consent.

7.3

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

7.4

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims

7.6

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.7

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.8

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may contact the Information Commissioner’s Office in the UK: https://ico.org.uk/global/contact-us/

7.9

You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 7.

8.0 Our details

8.1

This website is owned and operated by Peter Spanton Drinks Limited.

8.2

We are registered in England and Wales under registration number 09153373, and our registered office is at 18 Iliffe Yard, London, SE17 3QA

8.3

Our principal place of business is at 18 Iliffe Yard, London, SE17 3QA

8.4

You can contact us:

(a)

by post, to the postal address given above;

(b)

by telephone, on the contact number published on our website from time to time; or

(c)

by email, using the email address published on our website from time to time.